HMRC are proposing to extend the circumstances in which taxpayers must disclose uncertain tax treatments in their returns.
Not only does this add to the burdens on businesses, it offers no additional assurances as to the treatment they may be adopting. On the contrary, it emphasises areas that HMRC may wish to investigate.
Against that background, we will explore how businesses can seek to achieve certainty and how to mitigate risks when that is not possible.
We will consider:
- the rules requiring disclosure by taxpayers;
- practical insights from dealing with HMRC in relation to securing certainty;
- providing disclosure to HMRC; and
- addressing concerns that arise in adopting an uncertain tax position.
